1. ASK
1.1. We ask that the inspector Remove proposal to take Stadium out of MOL from the council's submitted core strategy
1.2. Proposal to remove Stadium from MOL is UNSOUND under pps12
1.2.1. not justified
1.2.1.1. Not based on a robust and credible evidence base
1.2.1.1.1. No consultation
1.2.1.1.2. No other type of factual evidence
1.2.1.1.3. No clear proposal
1.2.1.2. does not satisfy the stringent test for removal from MOL that is laid out in PPS12
1.2.1.2.1. has not provided evidence that this is the most appropriate course of action when compared with the most reasonable alternative
1.2.1.2.2. council has not provided description of "exceptional circumstances" required to take land out of MOL
1.2.1.2.3. Council has failed to show that it fails the criteria for inclusion in MOL
1.2.2. not effective
1.2.2.1. not deliverable
1.2.2.2. Ignores the Scrubs Act
1.2.2.3. Ignores council's duties as trustees
1.3. peroration
1.3.1. The Scrubs forms a unique whole in the life of londoners
1.3.1.1. users
1.3.1.1.1. sportspeople
1.3.1.1.2. bird watchers
1.3.1.1.3. kite-flyers
1.3.1.1.4. aircraft flyers
1.3.1.1.5. dog walkers
1.3.2. to think LCS is separable is like saying centre court at wimbledon is separable from the other courts because it has better facilities
1.3.3. spectators, showers, changing rooms
1.3.4. LCS is integral to the whole and should be protected under MOL designation as a part of that whole